Comment
Kansas has setback requirements of 2 miles from city boundaries and abandoned/active mine cavities but do not provide technical studies to justify. If these setbacks were adopted in Ontario it would eliminate the possibility of using existing solution-mined caverns. The approach in Germany is to require geological and engineering studies by the proponent to determine safe setbacks and establishment of monitoring programs. The German approach is preferable, with pre-operational testing to confirm pressure integrity of the storage container and an ongoing monitoring program after operations begin.The proponent should be required to prepare a development and operations plan for review and approval of MNRF similar to the requirement for new solution mining operations in S.9 of the Provincial Standards.
All geological evaluations must be done by a professional geoscientist licensed to practice in Ontario AND possessing demonstrated knowledge and experience in the subsurface geology of Ontario.
Any conversion of existing wells must meet the requirements of S.2.4 Injection Permits in the Provincial Standards.
Annual well licence fees must be paid and should be the same as for cavern storage and natural gas storage wells.
Geoscientific investigations required should include geology, hydrogeology, geochemistry, isopach and geological structure maps, geological cross-sections, conceptual geological model. At least one drill core of the roof rocks (30 metres) and storage interval should be obtained during drilling of the storage wells.
Notification requirement should be 1.6 km for any solution mining and/or hydrocarbon storage operations, as measured to the edges of the storage container and mined openings.
Requirements for observation wells should be the same as for natural gas storage.
Adoption of relevant sections of CSA Z341.
For storage operations is solution-mined caverns - Sonar surveys and subsidence monitoring should be required to monitor roof stability.
Consideration of requirement to prepare numerical model to predict response of rocks (eg. brittle failure) forming the storage container to the rapid pressure cycling associated with storage operations
[Original Comment ID: 211385]
Submitted February 12, 2018 12:01 PM
Comment on
Regulation change under the Oil, Gas and Salt Resources Act: Regulating compressed air energy storage in porous rock reservoirs and solution-mined salt caverns
ERO number
013-1613
Comment ID
1573
Commenting on behalf of
Comment status